I have a bit of a strange one here. We are having our stack emissions tested in the morning and the testing equipment is situated on a fixed platform around 30 foot above ground level. The platform is accessed via a fixed ladder. I have just been discussing the working platform with the contractor over the phone, and he insisted that if a fixed platform has guard rails, toe boards and self closing gates as listed in their method statement, then this is not classified as working at height, it is classed as a confined space. I found this comment quite shocking due to the fact that in my opinion even though controls are present on the platform (rails, gates etc), the risk of falling from height remains the same. I have checked the working at height regulations and I cannot find anything to say that a fixed working platform, if protected and controlled, is not classed as working at height. I am just looking to get a second opinion and see if anyone can shed any light on this particular scenario? I am 99.9% sure that a fixed platform 30 foot in the air is still classed as working at height or is there something I have been missing? Thanks James

Yup. Working at height. Control measures address the risk and reduce it significantly but not to the point where the risk disappears so much that they can no longer be said to be at height. Given that the control measures are in place, and competence arguments aside, is the argument just an academic one or has it some actual consequence for you and the contractor?

Certainly WAH but if there is a chance of a worker being exposed to asphyxiant vapours, gases, fumes etc then appropriate controls for those scenarios need to be in place. In practical terms, does it really matter what to call it, so long as the work can be done in safety and without health issues? It may be stretching it somewhat to class the platform at the top of a stack as a "confined space" but if it prompts people to think about the risks associated with these that may be present 30 ft above ground then that's OK to me.

Work via a fixed built in access gantries or platforms with guard rails, gates etc. with stair access can be classed as not working at height. The installation needs to meet the same criteria as you would expect on a mezzanine floor, landing etc. were the risks of falling have been controlled. However the fact that the platform is accessed via a fix ladder does in my opinion introduce a significant fall risk classifying it as work at height. The condition of the platform, weather could and nature of the work could all also introduce a significant fall risk. The confined space comment worries me as this does introduces a self-rescue requirement!

Alfasev has the WaH bit and to me the only issue is climbing the ladder. Once on the platform it's not WaH as such. Yes it's high up but that's all, the platform should be be fit for purpose. On the Confined Space bit - Think about this - Flue Gas Testing involves inserting lab instruments into the flue gas path of your stack - get that wrong and you're going to get a face full of whatever combustion product you happen to produce..... Gas/coal fired power station? Worse is energy from waste type installation. So, looking at the Confined Spaces regs then there is a foreseeable risk of a lack of oxygen or poisonous gasses although I grant in this case the space is not enclosed but the hazard is real enough.

Question. Confined space only having one entrance and exit, which has restricted access? Not the full definition I admit, and not the exact one, but, partially heading toward a confined space. Sounds like an elevated work platform accessed by a ladder to me. As far as the harness goes, unless you have a certified anchor point, then I don't think you can expect it to be used. Are you looking at fall restraint, or fall arrest. Have you & your contractor got a rescue plan if you are using fall restraint, you are insisting on the harness, so you should be assisting in this even though you are using a contractor. IMHO.

Edit *fall arrest* for the full rescue plan more than restraint. Oh for an edit facility. Oh & I can't post for a long time again either, does anyone know how long the period between posts is BTW please. Sorry for that OT bit.

Paul, five minutes, it is easier to log out and back in. The reason given for this is the idiots who kept sending the 1000's of spam mail the other month. I don't blame them as they have to clear them and it spoils it for everyone else4.